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Investment Advisers

SEC3 offers an extensive suite of customizable compliance services for investment advisers, on either a one-time or recurring basis depending on your needs.

Examples of potential services include, but are not limited to:

  • Annual Compliance Reviews
  • Quarterly Compliance Reviews
  • Due Diligence Reviews
  • Risk Assessment and Gap Analysis
  • Compliance Testing and Analysis
  • Mock SEC Examinations
  • Compliance Training
  • Customized Compliance Services

Annual Compliance Review

For registered advisers, the Compliance Rule requires each adviser to review its policies and procedures, at least annually, to determine their adequacy and the effectiveness of their implementation. In Annual Compliance Review services, SEC3 can assist Chief Compliance Officers in every phase of the annual review process, from formulating a strategic plan, to conducting thorough assessments and testing of all aspects of the compliance program, to planning for next year's review. SEC3's Annual Compliance Review allows advisers to maximize available resources by fulfilling specific elements or the entire scope of the regulatory obligation. The Annual Compliance Review can conclude with a customizable, easy to read report and action plan.

Quarterly Compliance Reviews

Most advisers would prefer to diversify the strain on operational and financial resources of an annual review over the course of the year, which is why SEC3 offers its flagship service, the Quarterly Compliance Review, as the perfect solution. Quarterly Compliance Reviews conduct all the aspects of the annual review over the course of the year in manageable phases while revisiting critical and changing areas throughout the year. The dynamic scope and disciplined approach of Quarterly Compliance Reviews stimulates the evolution of the compliance program, keeping it continually current and addressing any issues as they appear. Quarterly Compliance Reviews optimize compliance resources and limit the interruption of your firm. Like the Annual Compliance Review, each Quarterly Compliance Review can conclude with a customizable, easy to read report and action plan.

Additionally, Quarterly Compliance Reviews address the essential, on-going demands of a compliance program, such as managing disclosure documents, filing requirements, and compliance policies and procedures. Quarterly Compliance Reviews provide the opportunity for SEC3's professionals to establish a deep partnership with each adviser and fund and actively participate in the compliance program.

Risk Assessment & Gap Analysis

The Risk Assessment & Gap Analysis not only fulfills regulatory expectations, it provides valuable insights into your risk profile and your exposure to those risks. SEC3's Risk Assessment & Gap Analysis is a system that considers the likelihood and impact of the compliance risk specific to each advisory firm or fund and assesses how well the existing controls mitigate those risks. The Risk Assessment & Gap Analysis report is a concise, but detailed summary in plain English that prioritizes risks by exposure, arming the Chief Compliance Officer and Independent Directors with the critical information to immediately implement an action plan.

Compliance Testing & Analysis

Forensic tests are the eyes and ears of the Chief Compliance Officer. Without rigorous, consistent forensic testing, a Chief Compliance Officer has no early warning systems. Various forensic tests are means to identify symptoms of potential compliance problems and can serve as confirmation that the compliance program is functioning properly. SEC3 can assist Chief Compliance Officers in designing and conducting a battery of rigorous and periodic forensic compliance tests as part of the continuous monitoring of the compliance program; including, but not limited to, trading and execution, portfolio compliance, code of ethics, account administration, and investment performance.

Mock SEC Examinations

Much of the fear surrounding a regulatory examination stems from the "unknown" element. A Mock SEC Examination is an effective process to gauge the types of exposures and concerns that an adviser or fund would face during a real regulatory examination. Mock SEC Examinations use current exam focuses, with proven exam approaches and methodologies, including interviews, reviews of policy and procedures, analysis, and testing, and conclude with a customizable summary of assessments, recommendations, and proposed solutions. SEC3's professionals, with years of experience as senior examiners with the Securities and Exchange Commission or as compliance professionals, provide expert insight and guidance. Mock SEC Examinations pierce the mystique of a regulatory examination and transform an often stressful experience into a valuable assessment process that allows a Chief Compliance Officer and the compliance staff to face a future regulatory examination with confidence and peace of mind.

Compliance Training

Drafting and adopting reasonable policies and procedures is only part of the successful implementation of a compliance program; effective compliance training is also essential. The success of a compliance program is predominately determined by the ability of the adviser's or fund's staff to consistently fulfill the goals and functions of the policies and procedures. SEC3's professionals will assist Chief Compliance Officers in developing and conducting customized training programs to your staff on the various aspects of your compliance program and their responsibilities under that program. Our belief is that training should rejuvenate the staff's awareness and sensitivity of compliance policies while reinforcing the importance of each person's role in the compliance program.

Other customized services include:

  • Development and Implementation of Customized Compliance Policies and Procedures
  • Compliance Calendar & Planning Assistance
  • SEC Examination and Inquiry Response
  • Deficiency Letter Response and Remedial Action Plans
  • Form ADV and IARD Filings and Reviews
  • Registration Assistance: State and Federal
  • Disclosure Reviews

Newsletter

Get the latest compliance news and insights - delivered weekly. The SEC3 Communique covers all compliance topics. CCO3 focuses on Mutual Fund CCO topics.
tip: check both to keep informed!

Communiques

What the SEC’s New Cybersecurity Guidance Means for Investment Advisers and Inve…

By Janaya Moscony, CFA; Irshad Karim; Linda Smith; Claire Owens, SEC Compliance Consultants Published: NSCP Currents May 2015 The SEC has made cybersecurity a significant point of interest for 2015 through their... read more »

SEC Sanctions Investment Adviser for Failure to Devote Resources to Compliance F…

The SEC recently settled a proceeding brought against an investment adviser firm, its former President, and other principals at the firm where the compliance function was not adequately staffed and... read more »

SEC Proposes Extensive Amendments to Form ADV as Well as New Reporting Requireme…

On May 20, 2015, the SEC unanimously approved extensive proposed amendments to Form ADV that, if adopted, would require registered investment advisers to provide new information, including additional disclosure relating... read more »

SEC Continues Heavy Focus on Private Equity

The SEC is continuing to focus heavily on the private equity sector, reminding advisers in this space to be mindful of their practices. On May 13, 2015, Mark Wyatt, Acting... read more »

SEC Issues New Cybersecurity Guidance for Investment Advisers and Investment Com…

The SEC’s Division of Investment Management recently released new guidance to registered investment advisers and investment companies regarding cybersecurity. The SEC has previously identified cybersecurity as an important issue and... read more »

Your CCO May Now Have An Incentive to Turn You In

The Securities and Exchange Commission today announced an award of more than a million dollars to a compliance officer who believed that disclosure to the SEC was necessary to prevent... read more »

Events

GAIM Ops Cayman 2015

When: April 26-29th, 2015 Where: Ritz Carlton, Seven Mile Beach | Grand Cayman, Cayman Islands

Miami Compliance Roundtable

When: March 30th 2015 Where: Kaufman Rossin Fund Services | 2699 Bayshore Drive, Miami FL 33133

Dallas CCO Compliance Roundtable

When: March 05, 2015 Where: The Crescent Club | 200 Crescent Court, 17th Floor, Dallas, TX 75201